David Abbott |
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Mayer Brown1675 Broadway New York, NY 10019-5820 US Tel: +1 212 506 2642 Fax: +1 212 849 5642 Email: dabbott@mayerbrown.com Website: www.mayerbrown.com David Abbott is a highly respected tax litigator and transactional lawyer. He advises clients across a broad range of critical issues, with a particular focus on key areas of corporate concern involving tax litigation. David's dispute resolution practice emphasises tax litigation and controversy, as well as bankruptcy disputes. He has experience with tax audits and appeals, and represents clients before the US Tax Court and the US Court of Federal Claims. David's current and past cases involve corporate acquisition-related issues, payment of acquisition-related fees and financing-related issues such as debt versus equity characterizations, debt/equity swaps, transfer pricing and tax treatment of leasing transactions, including LILOs and SILOs. In addition, David has represented equity investors in chapter 11 bankruptcy cases involving several leading airlines with respect to aircraft lease tax indemnity agreement claims. Straddling his tax litigation and transactional work, David has extensive experience with valuations of business enterprises plus tangible and intangible assets. He works regularly with valuation experts to document and justify appraisal conclusions and present or defend them in tax audits and litigation. On the transactional side, David represents equity investors, lenders and lessees in equipment and real estate leasing transactions such as sale-leasebacks, leveraged and single-investor leasing, cross-border lease arrangements, acquisition and divestiture of leasing portfolios and leasing subsidiaries and related tax-oriented financing structures and debt instruments. His transactional tax counsel also encompasses acquisitions and divestitures, financial products, consolidated return regulations, general corporate taxation and partnership taxation. Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level." 
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Brad Anwyll |
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PwC600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: + 1 202 414 4326 Email: brad.anwyll@us.pwc.com Website: pwc.com/taxcontroversy Brad Anwyll is a principal in the transfer pricing group of the firm's national tax services (NTS) practice. Brad has more than 30 years of experience in tax controversy and litigation matters involving federal and international issues. He has participated in numerous cases before the Internal Revenue Service's Advance Pricing & Mutual Agreement Programme, examination division, and Appeals Office and has litigated more than 30 cases before the US Tax Court, the US Court of Federal Claims, the Federal District Courts, and the US Courts of Appeals. Brad has represented clients from a variety of industries including telecommunications, consumer products, oil and gas, pharmaceutical, and chemical manufacturing. Brad has been recognised as one of the country's leading tax controversy and litigation practitioners by Chambers USA for national tax litigation in 2008, by the Legal 500 for tax controversy in 2007, and by Washington, DC Super Lawyers in 2007. He also has received an AV rating from Martindale-Hubbell – its highest peer review rating. Brad is a fellow of the American College of Tax Counsel and a member of the American Bar Association's tax section, where he served as a member of the Tax Court Appointments Committee and chairman of the Court Procedure and Practice Committee. He is also a member of the Federal Circuit Bar Association and the Court of Federal Claims Bar Association, where he served as chairman of the tax section. Brad has written a number of articles on tax controversy issues and was co-author of the 1999-2003 'Cumulative supplements to litigation of federal civil tax controversies' (Warren, Gorham & Lamont, 2d edition, 1997). He also is a frequent speaker at national tax conferences and seminars. Brad received his JD, with distinction, from the Duke University School of Law and a BA with university and departmental (economics) honours, from Johns Hopkins University. Following law school, Brad was a judicial clerk to the Honourable Marion Bennett of the US Court of Appeals for the Federal Circuit. 
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Gregory Barton |
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PwC1 North Wacker Drive Chicago, IL 60606 US Tel: +1 312 298 6084 Email: greg.barton@us.pwc.com Website: pwc.com/taxcontroversy Greg is a principal in PwC's national transfer pricing practice. He has significant controversy and planning experience pertaining to transfer pricing, licensing, cost sharing arrangements, and other cross-border movement of tangible and intangible property and services. Greg also has extensive experience with advance pricing agreements (APAs), competent authority negotiations, and mediation. His controversy experience includes audits, administrative appeals, and litigation of federal tax disputes, with an emphasis on transfer pricing of tangible and intangible goods and services, and litigation and controversy experience with respect to related issues such as penalties, documentation and summonses. He has also handled several audits and appeals in recent years involving transfer pricing with respect to intercompany financing transactions and structures, including debt/equity and interest rate controversies. Recently, Greg has helped a US-based client organise and centralise all of its worldwide tax controversy and compliance functions into its headquarters. Relevant recent industry experience includes controversies in the pharmaceutical and medical device industries, as well as in branded consumer foods, semiconductors, chemicals, automobile parts, and high value services transactions. Before joining PwC in 2011, Greg was a partner at Mayer Brown in Chicago, where he practised law for 24 years. He is a member of the Illinois Bar; US Tax Court; and the US Court of Federal Claims. He received his JD with honours from the University of Chicago Law School. He also holds an MS in computer science from the University of Southern California, where he did work in the field of public key cryptography, and a BS in electrical engineering (summa cum laude) from the University of Notre Dame. Greg clerked for Judge Richard Posner on the US Court of Appeals in Chicago, and was an attorney at the White House Budget Office before joining Mayer Brown.
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Howard Berman |
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Deloitte Tax2 Jericho Plz Jericho, NY 11753-1683 US Tel: +1 212 436 2242 Email: hberman@deloitte.com Website: www.deloitte.com Howard is a member of Deloitte Tax's controversy services team. Howard specialises in representing clients before the Internal Revenue Service (IRS) and in coordinating complex IRS examinations and appeals for multinational corporations. Howard has significant experience handling inbound and outbound transfer pricing matters, was one of the first practitioners to use alternative dispute resolution techniques (that is, third party mediation) with the IRS and regularly uses fast-track settlement and other alternative dispute resolution techniques to negotiate the resolution of complex tax disputes for his clients. In addition to transfer pricing issues, Howard has helped clients resolve issues surrounding the treatment of debt financing structures, the allocation of interest and other deductions to US source activities, the determination and computation of taxpayers' Subpart F income and the correct information reporting of transactions between US and related foreign entities. For more than 20 years, Howard has represented clients in a variety of industries, including financial services, heavy manufacturing, pharmaceuticals, media and retail. Howard served as a senior trial attorney for the US Department of the Treasury, and represented the IRS before the United States Tax Court. While representing the IRS, Howard served as industry counsel for the financial services and LBO/merger and acquisition industries. In his tenure at the US Department of the Treasury, Howard helped to develop the Coordinated Examination Programme, and, in that capacity, advised many IRS agents and appellate officers with respect to the development of cases and the resolution of technical issues. Howard also has significant experience in IRS practice and procedure, penalty and quality control issues and has spoken and written extensively with respect to numerous IRS practice and procedure issues. Howard has a JD from the State University of New York at Buffalo – Faculty of Law and Jurisprudence, and a BA from Brandeis University. 
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Cabell Chinnis |
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Mayer BrownTwo Palo Alto Square, Suite 300 3000 El Camino Real Palo Alto, CA 94306-2112 US Tel: +1 650 331 2020 Fax: +1 650 331 4520 Email: cchinnis@mayerbrown.com Website: www.mayerbrown.com Cabell Chinnis specialises in audits and appeals, especially in the contentious area of transfer pricing. He has obtained speedy and favourable results by identifying key issues in the case and resolving them. He also has significant experience in advance pricing agreements and tax treaties. In audit, Cabell provides advice on working with the exam teams in special situations, preparing executives and other business personnel for interviews by the IRS or their experts, coordinating presentations to the exam team and resolving discovery disagreements with the exam team or Department of Justice. Cabell has successfully advised clients on how best to escalate within the IRS to senior agency personnel to facilitate resolution of audit issues. In appeals, Cabell specialises in handling complex matters and expediting resolution of issues if they are more limited in scope. His cases since January 1 2013 have involved section 482 issues in a variety of areas (services, tangible goods, transfers of intangibles), valuation disputes, R&E credit, and section 199. Cabell also handles tax-related alternate dispute resolution, including fast-track and 'limited issue' audits. In addition, he counsels tax exempt entities on a full range of matters, including their organisation, operation and sponsorship. Cabell began his nearly 30-year career by serving as a judicial clerk at the US Supreme Court for The Hon. Louis Powell, Jr. Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."
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Kenneth Clark |
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Fenwick & West801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7215 Fax: +1 650 938 5200 Email: kclark@fenwick.com Website: www.fenwick.com Kenneth Clark is a partner in the tax group of Fenwick & West and chairs its tax litigation practice. Fenwick has received numerous accolades for its tax controversy practice, including recognition by International Tax Review as US Tax Litigation Firm of the Year in three different years. The principal focus of Kenneth's practice is complex federal tax litigation and tax controversy work. He regularly practises in the US Tax Court and has published a number of articles relating to tax controversies. Fenwick & West has worked on more than 70 federal tax litigations. Kenneth has worked on numerous high profile tax controversy matters, for clients such as Xilinx, The Limited, Limited Brands, Textron, Apple, Daimler, GM Trading, Dover Corporation Adaptec, Analog Devices and CBS. With more than three decades of experience, Kenneth has also managed a variety of complex commercial disputes in a number of foreign countries and more than 20 states. Litigation prevention and alternative dispute resolution (ADR) have also been important parts of his practice. He has served as Fenwick & West's ADR coordinator, as an American Arbitration Association arbitrator, and has been involved in numerous mediations and arbitrations. Kenneth received a BA from the University of Redlands, where he graduated summa cum laude, and was first in his class. He received a JD from New York University School of Law, cum laude, and was a member of that school's Law Review. Kenneth also received an MBA from the University of California at Berkeley. He has extensive experience in teaching speaking techniques. Kenneth is a member of the state bars of California and New York and is admitted to practice in numerous federal courts. 
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Ward Connolly |
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PwC488 Almaden Boulevard San Jose, CA 95110 US Tel: +1 408 817 8234 Email: ward.connolly@us.pwc.com Website: pwc.com/taxcontroversy Ward Connolly is a principal in PwC's national tax services group and is resident in the firm's Silicon Valley technology centre of excellence in San Jose, California. Ward leads PwC's advance pricing, mutual agreement and transfer pricing controversy practice in the West region of the US. Ward has more than 15 years of experience as a tax professional and has represented US and foreign multinational corporations in complex tax audits, administrative disputes (IRS Appeals), alternative dispute resolution (fast-track), advance pricing agreements (APAs) and litigation. Ward has been recognised as one of the world's leading tax controversy advisers by International Tax Review and one of the best lawyers in the San Francisco Bay Area by Bay Area Lawyer Magazine. Ward has also been recognised in International Tax Review's World Tax for his skills in transfer pricing. Before joining PwC, Ward was a partner at Fenwick & West. Ward was previously a faculty member in the department of economics at Trinity University in San Antonio, Texas. Ward earned his JD, with honours, from Duke University, and his PhD in economics and his BA from the University of South Carolina. Ward is a member of the California Bar Association and has authored many technical articles for trade journals and other publications. Ward frequently speaks for professional tax groups, including numerous chapters of the Tax Executives Institute and BNA/CITE, and has instructed a class on transfer pricing controversy for San Jose State University.
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Thomas Durham |
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Mayer Brown71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7216 Fax: +1 312 706 9187 Email: tdurham@mayerbrown.com Website: www.mayerbrown.com Since joining the firm in 1980, Tom Durham has established a substantial and respected tax controversy practice. He represents taxpayers before the Internal Revenue Service and various state and local taxing authorities, including contested hearings of State of Illinois and City of Chicago taxes. He also acts on behalf of taxpayers in the US Tax Court, US Court of Federal Claims, and all levels of the federal court system. Tom has a particular focus on litigation of foreign tax issues, leasing, section 482, tax-advantaged investments, and economic substance issues. He also represents clients in appellate matters and summons enforcement litigation and has argued appeals in five different federal circuits. Tom also provides tax counseling, with an emphasis in two focused areas. He advises and represents tax-exempt organisations regarding federal and state tax issues that affect them, including qualification problems and the application of the unrelated business tax and also represents religious institutions with regard to their unique tax problems. He is also knowledgeable about natural resources tax law, representing owners and developers of natural resources with particular regard to the special tax problems of oil, gas, coal, and timber properties. Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."
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David Ernick |
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PwC600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: +1 202 414 1491 Fax: +1 678 529 5130 Email: david.ernick@us.pwc.com Website: pwc.com/taxcontroversy David Ernick is a principal in the transfer pricing practice of PwC's Washington National Tax Services office. Before joining PwC, David was associate international tax counsel at the US Treasury Department. While at Treasury from 2004-2013, his responsibilities included negotiating tax treaties and trade agreements, drafting regulatory guidance, and advising on legislative matters. He also represented the US as a delegate to the Organisation for Economic Cooperation and Development (OECD) Working Party No 6 on Transfer Pricing, and served as the chairman of its Special Session on Business Restructurings. David was the principal staff attorney for transfer pricing matters at Treasury, and advised on every significant guidance project in this area released by Treasury and the OECD during his tenure, including the final regulations on cost sharing arrangements and controlled services transactions. Before joining Treasury, David practised as a tax associate at Cravath, Swaine & Moore in New York and at WilmerHale in Washington. He has clerked at the US Tax Court and the US Court of Appeals for the Eleventh Circuit. He now serves as an adjunct professor and teaches a course on transfer pricing in the Graduate Tax Programme at Georgetown University Law Center. He is also a co-author of the 2014 Practising Law Institute's (PLI) Transfer Pricing Answer Book and a member of both the Bloomberg BNA Transfer Pricing Advisory board and the Tax Management International Journal's Panel of Leading International Tax Practitioners.
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David Forst |
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Fenwick & WestSilicon Valley Centre 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7254 Fax: +1 650 938 5200 Email: dforst@fenwick.com Website: www.fenwick.com David Forst is the practice group leader of the tax group of Fenwick & West. He is included in Euromoney's Guide to the World's Leading Tax Advisers. He is also included in Law and Business Research's International Who's Who of Corporate Tax Lawyers (for the last six years). David was named one of the top tax advisers in the western US by International Tax Review, is listed in Chambers USA America's Leading Lawyers for Business (2011-2014), and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine. David's practice focuses on international corporate and partnership taxation. He is a lecturer at Stanford Law School on international taxation. He is an editor of and regular contributor to the Journal of Taxation, where his publications have included articles on international joint ventures, international tax aspects of mergers and acquisitions, the dual consolidated loss regulations, and foreign currency issues. He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on international issues. David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives Institute, and the International Fiscal Association. David graduated with an AB, cum laude, Phi Beta Kappa, from Princeton University's Woodrow Wilson School of Public and International Affairs, and received his JD, with distinction, from Stanford Law School.
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Jim Fuller |
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Fenwick & West801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7205 Fax: +1 650 919 0942 Email: jpfuller@fenwick.com Website: www.fenwick.com Jim Fuller is a partner in the tax group at Fenwick & West in Mountain View, California. He has been included seven times as one of the world's top 25 tax advisers in Euromoney's Best of the Best and has regularly appeared in Euromoney's World's Leading Transfer Pricing Advisers. Jim also is the only US tax adviser to receive a Chambers star performer rating (higher than first tier), Chambers USA (2014). Chambers Global (2014) has Jim as one of only two US tax attorneys in the first tier in both the corporate tax and international tax categories. In 2013, Euromoney named Jim one of the US's top 30 transfer pricing advisers. In 2014, International Tax Review named Fenwick & West as first tier in transfer pricing (World Transfer Pricing 2014). Jim and his firm have served as counsel in well over 100 large-corporate IRS appeals proceedings and more than 70 federal tax court cases. Many have involved transfer pricing. International Tax Review has named Fenwick & West US Tax Litigation Firm of the Year on three occasions. Fenwick & West has represented six of the Fortune Top 10 companies, more than 50 of the Fortune Top 100 and more than 100 of the Fortune 500 companies in federal tax matters. ITR named Fenwick & West San Francisco Tax Firm of the Year five times.
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John Hildy |
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Mayer Brown71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7769 Fax: +1 312 706 8785 Email: jhildy@mayerbrown.com Website: www.mayerbrown.com Tax controversy and litigationJohn has represented taxpayers in all stages of federal tax controversy, including pre-audit, audit, administrative appeals, and litigation. He is also experienced in representing taxpayers during IRS fast-track proceedings and in court-supervised mediation. John has also advised taxpayers in connection with competent authority negotiations, advance pricing agreements, and other tax treaty matters. International tax and transfer pricingJohn's practice focuses heavily on defending and structuring transactions with significant transfer pricing implications, including cross-border transfer pricing of tangible and intangible property, shared headquarter services, and cost sharing arrangements. He has advised both US taxpayers with respect to international tax implications of offshore operations (for example, subpart F manufacturing, section 936), as well as non-US taxpayers with respect to the implications of their US activities. Tax procedureJohn has extensive experience defending against civil and criminal tax penalties and in addressing evidentiary privileges in the tax controversy context, including the attorney client privilege and work product protection in the modern business environment in light of IRS policies concerning tax accrual work papers and FASB Interpretation (FIN) No 48. Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."
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Charles Hurley |
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Mayer Brown1999 K Street, NW Washington, DC 20006-1101 US Tel: +1 202 263 3260 Fax: +1 202 263 5260 Email: churley@mayerbrown.com Website: www.mayerbrown.com Chuck Hurley's practice is concentrated primarily on matters of tax-related litigation and advice. His professional experience includes more than 13 years' service (1990–2003) with the US Department of Justice's Tax Division, where he was responsible for preparing and conducting significant tax trials involving document-intensive, complex disputes. Chuck held first chair on two of the tax division's most prominent recent cases: Long-Term Capital Holdings v. United States and Trigon Insurance Co. v. United States. In addition, Chuck served as first chair on more than 20 other jury and bench trials dealing with tax-related issues. He was also lead counsel on numerous other cases that were resolved short of trial, and he handled numerous evidentiary hearings regarding injunctions and summons enforcement proceedings. Recently, Chuck has represented Eaton, Siemens, TIAA-CREF and Cargill, to name a few. Before working with the Department of Justice, Chuck held positions with two other prominent law firms. Earlier, he served as law clerk to The Honorable Alvin Krenzler, US District Court for the Northern District of Ohio. Since joining Mayer Brown in 2003, Chuck has focused on complex, document-intensive tax matters with the potential to be litigated. Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."
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Cynthia Hustad |
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Deloitte Tax555 Mission Street San Francisco, CA 94105-0920 US Tel: +1 415 783 5567 Fax: +1 415 783 8962 Email: chustad@deloitte.com Website: www.deloitte.com Professional experienceCindy is the west region tax controversy competency leader for Deloitte Tax and represents corporate clients before the IRS. During her 15-year tenure at Deloitte, Cindy has successfully represented many large and small clients, both at the examination and appeals levels, specialising in transfer pricing and international issues. Before joining Deloitte, Cindy was a special trial attorney with the IRS Chief Counsel's Office where she represented the IRS in the US Tax Court in more than 50 litigated cases. During her period at the IRS, Cindy also advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS involving a wide range of complex international and domestic corporate issues. Cindy also represented the government in litigating several large corporate tax and transfer pricing cases, including DHL v. Commissioner. Positions held
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Sharon Katz-Pearlman |
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KPMG345 Park Avenue New York, NY 10154 US Tel: +1 212 872 6084 Fax: +1 212 409 8270 Cell: +1 917 533 3375 Email: skatzpearlman@kpmg.com Website: www.kpmg.com Sharon Katz-Pearlman is the national principal-in-charge of KPMG's tax dispute resolution network in the US. She also serves as KPMG International's head of global tax dispute resolution and controversy, overseeing a network of dispute resolution specialists from KPMG's member firms. Sharon advises clients during all phases of the disputes continuum, from pre-dispute (for instance, audit readiness, voluntary disclosures and pre-filing assistance) through examination, appeals and alternative dispute resolution (ADR) processes. With more than 25 years of experience in the field, Sharon works with clients on all aspects of their IRS matters, dealing with a wide variety of domestic and international tax issues. Sharon's US practice focuses primarily on representation before the IRS, of multinational corporate clients and financial institutions, both domestic and international. She provides assistance in all facets of alternate dispute resolution (ADR), including pre-filing agreements, early referral and mediation, as well as traditional examination and appeals consulting. Sharon advises on disputes involving a wide range of technical issues including domestic corporate reorganisations, TEFRA matters, competent authority proceedings and transfer pricing issues. Before joining KPMG, Sharon was a special litigation attorney with the IRS Office of Chief Counsel, Manhattan District Counsel, advising many exam and appeals teams on varied issues. She was also responsible for the development and litigation of major tax matters before the US Tax Court and served on a number of litigation teams. While with the IRS, Sharon received the National Attorney of the Year award (the James Markham Memorial Award), presented annually to one field attorney in the country, for outstanding contribution to the Office of Chief Counsel. Sharon is a frequent presenter at tax conferences and has published a variety of industry articles on various domestic and international tax topics. 
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Andrew Kim |
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Fenwick & West801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7146 Fax: +1 650 938 5200 Email: akim@fenwick.com Website: www.fenwick.com Andrew Kim is a partner in the tax group of Fenwick & West. Andrew's practice focuses on both domestic and international corporate tax matters, with an emphasis on tax dispute matters. For example, Andrew served as counsel in the recent CBS case, and currently serves as counsel in Analog Devices v Commissioner in the US Tax Court. Andrew has significant experience in representing clients with respect to cross-border transactions, corporate restructurings, international joint ventures, transfer pricing, as well as dispute resolution matters. He has published articles on international tax issues and developments in the Journal of Taxation, International Taxation, the Euromoney Corporate Tax Handbook, and World Tax. Andrew frequently speaks on international tax issues at meetings for professional tax groups, including the Tax Executives Institute. Andrew was included by Euromoney among the World's Leading Tax Advisers (2014). Fenwick's tax practice has earned a reputation as one of the nation's leading domestic and international tax practices. International Tax Review recognised Fenwick in its first tier in both its World's Leading Tax Planning Firms and World's Leading Transactional Firms guides in 2014. Fenwick was also recognised by International Tax Review as US Tax Litigation Firm of the Year in three different years, and Americas M&A Tax Firm of the Year in 2012. Andrew received his JD, cum laude, from Harvard Law School, and BS in psychology with highest honours from the University of Illinois.
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Thomas Kittle-Kamp |
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Mayer Brown71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7028 Fax: +1 312 706 9197 Email: tkittlekamp@mayerbrown.com Website: www.mayerbrown.com Since joining Mayer Brown in 1990, Tom Kittle-Kamp has represented clients in all phases of tax controversy and litigation. His litigation experience includes the trial and appeal of major corporate cases involving section 482 allocations, substance-over-form theories, intangible assets, debt-equity characterisation, valuation disputes, capitalisation questions, subpart F and other international tax issues, subchapter C issues, and leasing transactions. Tom also maintains an extensive practice of advising and representing clients with respect to administrative matters, including IRS audits, IRS appeals (including fast track and appeals mediation procedures) and competent authority negotiations. He also represents corporate clients with respect to tax-sharing disputes. Tom has deep experience in all aspects of international transfer pricing, particularly matters involving intangible assets and intellectual property. He provides tax planning advice with respect to cross-border transactions involving intangible assets, goods and services; transfer-pricing documentation; and the development, exploitation and disposition of intangible assets, including licences, sales and cost-sharing arrangements. He is co-author of the treatise Federal Income Taxation of Intellectual Properties and Intangible Assets (Warren, Gorham & Lamont 1997), which is updated twice a year. Before law school, he worked for several years as a newspaper reporter. According to Chambers USA, Tom is "extremely confident and persuasive in the courtroom and a pleasure to work with." According to Legal 500, Tom is "a very rare combination – a subtle courtroom advocate and a real tax expert". Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."
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Brian Kittle |
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Mayer Brown1675 Broadway New York, NY 10019-5820 US Tel: +1 212 506 2187 Fax: +1 212 849 5987 Email: bkittle@mayerbrown.com Website: www.mayerbrown.com Since joining Mayer Brown, Brian Kittle has been a member of Mayer Brown's tax controversy and transfer pricing practice. Brian represents clients in all facets of tax controversy, including administrative proceedings, contested hearings, litigation and appellate matters. His controversy experience includes major corporate tax matters. Brian frequently assists clients in using IRS alternative dispute resolution initiatives, such as pre-filing agreements, and has broad experience handling audits and IRS appeals. Brian also has extensive experience defending against civil tax penalties and protecting taxpayers' evidentiary privileges, including the attorney client privilege and work product protection in the current business and IRS environment concerning tax accrual workpapers, in tax controversies. His litigation experience includes extensive trial work in various Federal Courts including the United States Tax Court, the United States Court of Federal Claims and several United States district courts, and appellate advocacy in various United States Courts of Appeals. ??Brian also has deep experience with all aspects of intercompany transactions. He has advised on intercompany financing arrangements as well as other tangible and intangible intercompany transfers of property. ??Before joining Mayer Brown, Brian began his career severing as law clerk and attorney adviser to Hon. Joseph Robert Goeke of the United States Tax Court from 2004 to 2006. ??Brian is regularly recognised as a leader and rising star in tax controversy and often speaks at conferences on tax controversy matters. Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 United States Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."
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Kenneth Klein |
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Mayer Brown1999 K Street, NW Washington, DC 20006-1101 US Tel: +1 202 263 3377 Fax: +1 202 263 5377 Email: kklein@mayerbrown.com Website: www.mayerbrown.com Kenneth Klein concentrates his practice on international taxation. His experience includes planning, structuring/restructuring, tax controversies, regulations, legislation, private letter rulings, and amicus briefs. He has represented domestic and international clients in numerous industries, including manufacturing, financial services, software, transportation, pharmaceuticals, services, real estate, agricultural, trading, and entertainment, among others. Ken has experience with outbound investments, inbound investments, income bifurcation and amalgamation, controlled foreign corporations (subpart F), investments in US property, intangibles, contract manufacturing, source of income, foreign tax credits, transfer pricing, portfolio interest, conduit financing arrangements, withholding tax, tax treaties, investment funds, derivatives, and stock and securities lending. He also has experience with the taxation of artists and athletes and international individual tax planning. Ken was co-chairman of Mayer Brown's tax transactions practice from 2006-2012. Before Mayer Brown, Ken worked at the IRS, first as attorney and then as assistant branch chief in the Legislation & Regulations division and the General Litigation division (1977-1981), and later as the associate chief counsel (Technical) (1988-1990). Ken was an associate and then a tax partner at Cadwalader, Wickersham & Taft from 1981-1988 and 1990-2002. He also was fellow of the American Society of International Law (1976-1977). Ken is recognised year after year for his skills in international taxation. He has been lauded by clients for his "sophisticated cross-border tax planning, structuring and restructuring for a number of US and non-US multinationals". He has also been named as a leading lawyer by Legal 500 for four consecutive years. For the past seven years, Ken has been named to the World's Leading Tax Advisers (Euromoney/International Tax Review). He is recognised as a leading tax controversy adviser in the International Tax Review Tax Controversy Leaders guide and named among the 'Best Tax Lawyers' in Washington DC by Washingtonian Magazine and Washington Post Magazine. Ken has also been featured as a leading tax lawyer in Washington DC by Super Lawyers for five consecutive years. Mayer Brown's tax practice is ranked Tier 1 by Chambers USA, Legal 500 and the International Tax Review. Ken is vice president of the Legal Aid Society of the District of Columbia and is on the Board of Visitors of the University of Georgia School of Law.
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Larry Langdon |
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Mayer BrownTwo Palo Alto Square, Suite 300 3000 El Camino Real Palo Alto, CA 94306-2112 US Tel: +1 650 331 2075 Fax: +1 650 331 4575 Email: lrlangdon@mayerbrown.com Website: www.mayerbrown.com Attorney Larry Langdon brings comprehensive experience in the areas of tax controversy and planning to clients' service. He is widely recognised for his knowledge of federal tax policies and applications and has been characterised by Chambers USA as "a great tax mind". Larry has been a speaker at the American Bar Association Section of Taxation, American Institute of CPAs, Manufacturers Alliance [MAPI], Tax Executives Institute and many other professional and industry groups. Larry joined Mayer Brown in 2003. Previously, he held senior positions with the US Internal Revenue Service (commissioner, Large & Mid-Size Business division, 1999–2003; Legislation and Regulations division, Office of Counsel, 1964–1968; and Joint Committee division, Office of Chief Counsel, 1961–1962) and, in the private sector, with leading firms such as Hewlett-Packard (VP, general transition manager, 1999; VP, tax, licensing and customs, 1978–1999); Vetco (director of taxes and corporate secretary, 1976–1978); and the Ford Motor Company (senior tax attorney, General Counsel's Office, 1968–1976). Larry also worked with the CARE organisation from 1962–1964. Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."
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Marc Levey |
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Baker & McKenzie452 Fifth Avenue New York, NY 10018 US Tel: +1 212 891 3944 Fax: +1 212 310 1644 Email: marc.levey@bakermckenzie.com Website: www.bakermckenzie.com Marc Levey is a partner in the New York office of Baker & McKenzie. He has more than 35 years of experience in international taxation and is a nationally recognised expert in his field, particularly in structuring and defending transfer pricing strategies. He has frequently been acknowledged by Euromoney in its World's Leading Tax Advisers guide and included in its Best of the Best global tax experts. Marc's practice focuses on transfer pricing and cross-border transactions; tax controversies and litigation; general corporate, international and partnership taxation, and restructuring multinational company's global operations. He has worked in various industries such as pharma/life sciences, financial institutions, energy, automotive, chemicals, electronics, consumer goods, gaming, fashion and luxury products. Marc serves on the US transfer pricing management committee, was the past chairman of the firm's global transfer pricing steering committee and is co-chair of the firm's luxury and fashion industry practice group. Marc previously served as tax attorney with the international tax ruling group of the National Office of the Internal Revenue Service (IRS) from 1975 to 1977. He acted as senior trial attorney with the Tax Division of the US Department of Justice from 1977 to 1981. He was the Special Attorney to the Attorney General of the US Department of Justice in 1982. Marc represents a wide range of clients in proceedings before the IRS and federal courts and has substantial experience in handling tax controversies. He has been, and still is, tax counsel to numerous significant Tax Court and US Claims Court cases and has also successfully negotiated conclusions to numerous IRS tax audits, appeals controversies, fast track appeals, competent authority matters and advance pricing agreements. Marc has been a featured speaker at numerous international tax seminars throughout the world. He is also the editor and author of tax treatises US Taxation of Foreign Controlled Business, co-author of International Transfer Pricing OECD Guidelines, Warren Gorman Lamont treatises, the co-author of Transfer Pricing: Rules, Compliance and Controversy 4th Edition, CCH Incorporated, the co-author of Transfer Pricing: Alternate Practical Strategies 890 Tax Management Foreign Income Portfolios (2001 and 2007), co-editor of Transfer Pricing and Dispute Resolution (IBFD 2011) and co-editor of Transfer Pricing and Intra-Group Financing (IBFD 2012). Marc has authored more than 180 publications over the last 20 years in leading global tax publications. He received his JD from University of Cincinnati College of Law in 1972 and his BS from Wilkes University in 1969. He received his LLM in taxation with honours from University of Miami Law School in 1983. He is admitted to practise in the states of New York, California and in the District of Columbia. 
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Darrin Litsky |
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Deloitte Tax1633 Broadway New York, NY 10019-6754 US Tel: +1 212 436 5760 Fax: +1 212 653 7883 Email: dlitsky@deloitte.com Website: www.deloitte.com Trained as a lawyer and a certified public accountant, Darrin Litsky is a transfer pricing specialist in Deloitte's New York office. Darrin has a diverse background of 25 years of professional tax and accounting experience with industry, Big 4 public accounting, major law firm, and the Internal Revenue Service's (IRS) advance pricing agreement (APA) programme. While in industry, Darrin served as the general tax counsel of a publicly owned telecommunications company and was responsible for its worldwide transfer pricing in more than 40 countries. Darrin served as a team leader for four years with the IRS APA programme. Including his time in government practice, Darrin has been substantively involved in more than 100 APA requests involving a variety of different countries and industries, including telecommunications and insurance. His transfer pricing practice is now primarily APA request representation, mutual agreement procedure (MAP) matters, and audit defence. Darrin is a recent past chairman of the Transfer Pricing Committee of the American Bar Association (ABA) Tax Section. Over the past 10-plus years, he served as the committee's chairman, vice-chairman, led subcommittees on APAs, intercompany services, and important developments, and received the committee's Outstanding Service Award for 2003-2004. In 2014, Darrin led an ABA task force that provided formal comments to the IRS on proposed procedures for obtaining an APA. Similarly, in 2005, Darrin was responsible for leading the ABA's formal comments to the IRS on the operation of the APA programme. As part of this effort, he provided oral testimony on the APA programme in a public hearing held in Washington. In 2004, Darrin led another ABA task force that provided formal comments on proposed Treasury regulations for transfer pricing of intercompany services. In 2006, Darrin contributed to the ABA's comments on temporary Treasury regulations for transfer pricing of intercompany services. Darrin holds a BS economics degree (magna cum laude) from The Wharton School and a JD degree from Georgetown University Law Center. He is a member of the District of Columbia Bar and a certified public accountant.
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Shawn O'Brien |
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Mayer Brown700 Louisiana Street Suite 3400 Houston, TX 77002-2730 US Tel: +1 713 238 2848 Fax: +1 713 238 4602 Email: sobrien@mayerbrown.com Website: www.mayerbrown.com Shawn O'Brien is a tax controversy partner who represents clients in all types of tax disputes with tax authorities at international, federal and state levels. He routinely advises clients on various tax issues during tax examinations, in administrative appeals and as an advocate in trial and appellate litigation before the US Tax Court, US district courts and US Court of Federal Claims. Shawn's tax controversy and litigation experience spans a broad range of areas, including transfer pricing controversies, debt versus equity issues, international withholdings, advance pricing agreements, tax shelter disallowances, estate and gift tax valuations, research and development tax credits, excise taxes, and changes in accounting methods. Shawn advises foreign and domestic corporations, partnerships, MLPs, and LLCs seeking corporate and tax advice in connection with various types of foreign and domestic transactions, including mergers and acquisitions, restructurings, divestitures, leveraged buyouts, structured financings, and oil and gas transactions. Shawn is particularly focused on tax issues facing the energy industry including tax controversy, joint ventures, restructuring, acquisition and disposition of energy assets. Shawn served as chairman of the committee for energy and natural resources of the State Bar of Texas Tax Section from 2011 to 2013. Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 United States Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level." Additionally, the practice has been honoured by International Tax Review in the past few years as Americas Tax Disputes Firm of the Year, US Tax Court Firm of the Year, US Transfer Pricing Firm of the Year, North America Transfer Pricing Firm of the Year, Chicago Transfer Pricing Firm of the Year, Dallas/Houston Tax Firm of the Year, San Francisco Area Transfer Pricing Firm of the Year, San Francisco Area Tax Firm of the Year, and Washington, DC Tax Firm of the Year. Shawn is a certified public accountant (CPA) licensed in Louisiana.
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Pam Olson |
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PwC600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: +1 202 414 1401 Fax: +1 678 529 1022 Email: pam.olson@us.pwc.com Website: pwc.com/taxcontroversy Pam is the deputy tax leader and Washington national tax services (WNTS) practice leader of PwC. In her role as WNTS leader, Pam leads a team that includes many former senior government officials and policy advisers. Before joining PwC, Pam retired as the leader of a major law firm's Washington office practice, and served as assistant secretary for tax policy at the US Department of the Treasury. Pam has represented clients in a broad range of matters, including IRS audits, appeals and litigation; congressional investigations; private letter ruling requests and other administrative guidance; and in the submission of comments on proposed regulations. She also has advised clients on tax and social security reform, legislative matters and the structuring of transactions. She is a frequent speaker on tax, economic and federal budget matters and has testified before several congressional committees. As assistant secretary for tax policy, Pam had supervisory responsibility for providing the secretary of the treasury with policy analysis and recommendations for all domestic and international issues of federal taxation, including legislative proposals, regulatory guidance, and tax treaties, and for providing the official estimates of all government receipts for the president's budget and treasury cash management decisions. Pam also held positions with the chief counsel's office of the Internal Revenue Service as special assistant to the chief counsel, attorney-adviser in the legislation and regulations division and trial attorney in San Diego District Counsel. In 2000 and 2001, Pam was the first woman to serve as chairperson of the American Bar Association Section of Taxation. She has served as tax and economic adviser to two presidential campaigns and as tax adviser to the National Commission on Economic Growth and Tax Reform. She has been included repeatedly in Chambers USA: America's Leading Lawyers for Business and The Best Lawyers in America for tax law. Pam served as a regent of the American College of Tax Counsel and on the board of several tax exempt organisations. She received distinguished service awards from the Federal Bar Association and from Tax Executives Institute and the Treasury Department's highest award. Pam received her BA, MBA, and JD from the University of Minnesota.
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Kimberley Peterson |
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Deloitte Tax225 West Santa Clara Street San Jose, CA 95113-2303 US Tel: +1 408 704 4041 Fax: +1 408 704 8074 Email: kimpeterson@deloitte.com Website: www.deloitte.com Kim Peterson is a director in the Silicon Valley office of Deloitte Tax's tax controversy services west region practice. During her six year tenure at Deloitte, Kim has successfully represented many corporate and partnership clients before the IRS, both at the examination and appeals levels, throughout the US. Kim specialises in transfer pricing and other cross-border and international issues. Before joining Deloitte, Kim spent 13 years with the IRS Chief Counsel's Office, as international field counsel, associate area counsel, and deputy area counsel for strategic litigation. While at the IRS, Kim advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS, involving a wide range of complex international and domestic corporate issues. Kim also represented the IRS in the US Tax Court in large case litigation involving transfer pricing and other international issues, including in the DHL v. Commissioner and Microsoft v. Commissioner cases, receiving western region and national litigation awards. As associate area counsel and deputy area counsel for strategic litigation, Kim had responsibility for large case litigation, including the special trial attorney litigation of Xilinx v. Commissioner and Veritas v. Commissioner. Kim is a member of the State Bar of California and is admitted to practice before the US Tax Court and the US Court of Appeals for the Ninth Circuit. Kim is a frequent speaker on IRS practice and procedure and the management of complex IRS examinations, especially transfer pricing examinations. Kim received her BS in business administration from the University of California, Berkeley, and her JD from the University of Arizona, James E. Rogers College of Law.
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Irving Plotkin |
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PwC125 High Street Boston, MA 02138 US Tel: +1 617 530 5332 Email: irving.h.plotkin@us.pwc.com Website: pwc.com/taxcontroversy Irving Plotkin, senior managing director of PwC's tax and economic controversy practice and a member of its national tax service based in Boston, is one of the premier experts in the field of transfer pricing and other complex domestic and international tax issues such as economic substance, financial products, and insurance. He specialises in analysis of the effects of various types of government regulation, self–regulation, and taxation on capital flows, output, prices, risk–taking, competition, and efficiency within individual industries. His work on risk/return measurement and on international and domestic tax issues is widely cited, as is his expert testimony on behalf of US and foreign taxpayers and the IRS/DOJ in many high-profile and precedent-setting tax disputes (including Du Pont, Xilinx, UPS, DHL, ACM, Bausch and Lomb, Dow [COLI], The Limited [NYS], Toys R Us [NYC], Cambridge Brands [Mass.], and the captive insurance cases). He has designed, directed, and published research involving microeconomics, finance, industrial organisation, and econometrics. He has presented the results of these studies before several US Senate and House committees, the Federal Reserve Board, the Interstate Commerce Commission, the Federal Maritime Commission, the Federal Trade Commission, US Claims, Tax, and District Courts, and numerous state legislative committees, courts, regulatory agencies, and arbitration panels. He has assisted in the writing of international tax legislation and regulations. Irv holds a BS in economics from the Wharton School (University of Pennsylvania) and a PhD in mathematical economics from the Massachusetts Institute of Technology, where he taught computer science and finance. He has presented numerous papers in several fields of economics and regulation before various academic societies, professional organisations and industrial associations and has served as an editorial reviewer for the Journal of the American Statistical Association, the Journal of Industrial Economics, and the Journal of Risk and Insurance. His published papers and monographs include 'Risk/Return: US Industry Pattern' (Harvard Business Review), 'Rates of Return in the Property and Liability Insurance Industry: A Comparative Analysis' (Journal of Risk and Insurance); The Consequences of Industrial Regulation on Profitability, Risk Taking, and Innovation; Torrens in the United States; and 'Economic Principles in Establishing Transfer Prices' (Tax Management, Foreign Income Portfolio, co-author). Irv's comments on current tax developments appear frequently in tax periodicals.
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Keith Reams |
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Deloitte Tax980 9th Street Suite 1800 Sacramento, CA 95814-2738 US Tel: +1 415 783 6088 Email: kreams@deloitte.com Website: www.deloitte.com Keith Reams is the US and global leader for clients and markets for Deloitte's global transfer pricing services practice. He has advised clients around the globe on intercompany pricing transactions with respect to income tax regulations in Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Columbia, Czech Republic, Denmark, France, Germany, India, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Malaysia, Mexico, the Netherlands, Norway, Peru, Poland, Singapore, South Africa, Spain, Switzerland, Taiwan, Thailand, the UK, and the US. He has assisted numerous multinational companies with international valuation and economic consulting services involving merger and acquisition activity, international tax planning, and restructuring and reorganisation of international operations. Keith is on the global tax management team for Deloitte's technology, media and telecommunications practice and is a leader in the area of transfer pricing for newly emerging industries, such as electronic commerce and cloud computing, where he has extensive experience around the world in helping clients extend their business models into new territories. Keith has testified as a qualified expert in numerous valuation and transfer pricing disputes, including the cases of Nestle Holdings Inc. v. Commissioner; DHL Corp. v. Commissioner; and United Parcel Service of America, Inc. v. Commissioner. In addition, he is one of only three economists in the US approved by the New York State Department of Taxation and Finance to provide transfer pricing expertise and testimony in cases involving cross-border transactions within commonly controlled affiliated groups. He has also helped many clients to successfully resolve valuation and transfer pricing disputes before they reach trial. EducationKeith completed course requirements for a PhD in international finance from New York University. He holds a master's of arts degree in economics from California State University Sacramento and a BS degree in chemical engineering from Stanford University.
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William Schmalzl |
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Mayer Brown71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7225 Fax: +1 312 706 9202 Email: wschmalzl@mayerbrown.com Website: www.mayerbrown.com William Schmalzl focuses on tax litigation, corporate tax planning and state tax advice. He represents clients in all stages of tax litigation including audits, administrative proceedings, US Tax Court, federal district court and courts of appeals and Illinois state courts. The issues he has litigated include IRC section 482, the investment tax credit, research tax credit, sale-leasebacks, foreign tax credits, franchises, patents and other intangibles. William's undergraduate majors in economics and mathematics have proven invaluable in the preparation of expert reports and in the examination of expert witnesses at trial. William's trial experience includes Seagate Technology, National Semiconductor, United Parcels Service, RJR Nabisco, ConEd and Flextronics. Before he joined Mayer Brown, William served as a clerk to the Honourable Robert Ainsworth, Jr, of the 5th Circuit Court of Appeals (1977-1978). Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level".
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Ronald Schrotenboer |
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Fenwick & West LLPSilicon Valley Center 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7207 Fax: +1 650 938 5200 Email: rschrotenboer@fenwick.com Website: www.fenwick.com Ronald Schrotenboer is a partner at Fenwick & West, practising in the area of taxation. Ronald practises out of the firm's Mountain View office in California. His practice includes both domestic and international federal income tax as well as state income and sales tax. A significant part of his practice includes tax planning for pending transactions. He represents both US-based companies in domestic and international transactions, as well as foreign based companies with operations in the US. He also has been, and continues to be, involved with many Internal Revenue Service and state income tax audits, appeals and tax court cases, including §482 transfer pricing cases. His published decisions include Xilinx, Inc. v. Commissioner, (stock option amounts not required to be cost shared under § 482); Sun Microsystems v. Commissioner (incentive stock option deduction qualifies for R&D credit); appeal of Finnigan Corporation, (throwback rule is applied on a unitary basis; appeal of Joyce overruled); petition of Intel Corporation, (technology transfers are not subject to California sales tax). Ronald has written articles on various tax topics for the Journal of Taxation, Tax Notes, Taxes International, the Journal of State Taxation and other periodicals. He has spoken for many tax groups including the Alliance for Tax Legal and Accounting Seminars, The Council on International Tax Education and Tax Executive's Institute. He has also taught a graduate course at Golden Gate University on the taxation of high technology and a graduate course at San Jose State University on sales taxation. Ronald received his BA degree with honours in 1977 from Calvin College in Grand Rapids, Michigan. He received his JD degree magna cum laude from the University of Michigan in 1980. He graduated as a member of the Order of the Coif and was an editor on the Michigan Law Review for two years.
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Barry Shott |
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PwC300 Madison Avenue New York, NY 10017? US Tel: +1 646 471 1288 Fax: +1 813 741 5278 Email: barry.shott@us.pwc.com Website: pwc.com/taxcontroversy Barry Shott, senior managing director, is a member of PwC's national tax services practice and co-leader of its advance pricing & mutual agreement (APMA) and transfer pricing controversies practice. Barry joined PwC after a lengthy career with the IRS in a wide range of field examination and executive level positions. Barry is now responsible for assisting clients in resolving matters before the United States Competent Authority in the Mutual Agreement Process and obtaining advance pricing agreements (APAs). He also assists large multinational clients and high wealth individuals in avoiding and resolving disputes before tax returns are filed, during their examination, and afterwards in the appeals process. Barry is a CPA in New Jersey and New York, is a member of the American Institute of Certified Public Accountants, and serves on the AICPA's IRS Advocacy & Relations Committee. Immediately before joining PwC in April 2010, he was a top-level executive at the IRS, serving as the United States Competent Authority (USCA) and deputy commissioner (International) in the large & mid-size business division (now LB&I). As the Competent Authority, Barry provided leadership and direction to US negotiators in resolving bilateral disputes between the US and its treaty partners. As the deputy commissioner he was responsible for all matters of international taxation for the IRS and served as the adviser to the commissioner of internal revenue on all international tax administration matters and bilateral relationships with treaty and information exchange (TIEA) partners. He was a frequent public speaker and panelist and participated in initiatives with the Forum on Tax Administration at the Organisation on Economic Cooperation and Development (OECD) and the Inter-Americas Center for Tax Administrations (CIAT). Before his top-level leadership roles Barry served as a financial services industry director of field operations and as the industry director for the financial services industry in New York and in California as the director of the communications, technology and media industry. In 2009 he received the prestigious Presidential Rank Award for meritorious service as an executive leader at the IRS.
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George Soba |
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Deloitte Tax191 Peachtree St Ste 2000 Atlanta, GA 30303-1749 US Tel: +1 404 220 1153 Email: gsoba@deloitte.com Website: www.deloitte.com George Soba is a principal in Deloitte Tax's transfer pricing practice. George has more than 16 years of experience with Deloitte Tax representing US and foreign multinational clients in transfer pricing controversies (audits, appeals, and Competent Authority proceedings between the United States and foreign tax authorities), and in advance pricing agreements (APAs). He advises clients on the transfer pricing aspects of global tax rationalisation, planning, documentation, and audit defence preparation. George's industry experience includes aerospace; consumer goods companies (retailers, distributors, and manufacturers); e-commerce; financial transaction processing and electronic trading exchanges; healthcare (vertically integrated pharmaceutical companies, biotech, and medical instruments) and contract research organisations; heavy manufacturing (construction equipment, printing, automotive companies, and automotive parts manufacturers); REITs; and, technology (wafer manufacturers, chip design and manufacturing, internet-related optical routers, servers, and infrastructure). Before joining Deloitte, George worked as a field attorney for nine years in the IRS Office of Chief Counsel, served as an advisor to IRS examination teams conducting transfer pricing audits, advised appeals officers on the resolution of transfer pricing matters, served as one of the first IRS field attorneys on APAs, was on the IRS litigation team for the Perkin-Elmer transfer pricing trial before the US Tax Court, and was seconded to the IRS APA programme where he served as a team leader during the establishment of the APA programme. He then worked for two years in the Office of Associate Chief Counsel (International) advising large-case examination teams on transfer pricing issues, evaluating transfer pricing controversies for potential litigation by the IRS, advising the US Competent Authority on transfer pricing, permanent establishment, and business profits issues, and as a team leader in the APA programme. George is a frequent speaker on transfer pricing topics and has authored and coauthored papers on transfer pricing audits, blocked income, APAs, and other topics. He holds an LLM in tax from New York University School of Law, and is a member of the American and Washington, DC Bar associations.
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Scott Stewart |
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Mayer Brown71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7821 Fax: +1 312 706 9203 Email: sstewart@mayerbrown.com Website: www.mayerbrown.com Scott Stewart's practice is focused exclusively on tax disputes and transfer pricing matters. He represents taxpayers at all levels of federal tax controversy, including audits, administrative appeals before the Internal Revenue Service, mediation involving the appeals division of the IRS, and litigation before the US Tax Court. Recognised by Chambers USA each year from 2006 through 2014, Scott is described as "a talented litigator and corporate adviser" who wins the confidence of clients with his "extraordinary communication skills" and "broad and deep experience." He is "recommended for his spot on judgment and analysis," "his responsiveness and strategic thinking" and his "ability to anticipate issues before they arise." Chambers notes that he is "particularly adept at handling transfer pricing cases at all levels." Similarly, Euromoney recognises Scott in its 'Guide to the World's Leading Tax Advisers' and Legal 500 recognises his "wide range" of experience and cites his "very strong reputation" in tax controversy. Scott has extensive experience with deductibility of interest expense in related-party transactions, including debt-versus-equity characterisation and sham transaction and economic substance issues, dating back to his involvement in the landmark Nestlé Holdings case during the 1990s. Recently, Scott led the Mayer Brown team that filed 15 Tax Court petitions concerning debt-equity issues on behalf of Tyco International and related companies. The cases involve $3 billion in interest expense incurred from 1998 through 2000 and potentially implicate nearly $10 billion in interest expense incurred over a period of 10 years, according to the companies' public statements. Scott is also experienced in all aspects of international transfer pricing, including cross-border movements of tangible and intangible property, advance pricing agreements, cost sharing arrangements, section 6662 documentation, transfer pricing litigation, and issues related to section 936 Puerto Rico possessions corporations. His transfer pricing litigation experience includes a number of the major cases of the past two decades, such as National Semiconductor, Seagate Technology, Nestlé Holdings and United Parcel Service. Scott's experience also includes acquisition-related issues, such as valuation of tangible and intangible assets. He advises clients on tax treaty matters, competent authority issues, attorney-client and related privilege issues, civil and criminal tax penalties, and accounting for tax matters under FIN 48 of the Financial Accounting Standards Board. His industry experience includes manufacturing, pharmaceutical, medical device and food processing companies. Scott holds a JD from Harvard Law School and an MBA from the Johnson Graduate School of Management at Cornell University.
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David Swenson |
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PwC600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: +1 202 414 4650 Email: david.swenson@us.pwc.com Website: pwc.com/taxcontroversy David Swenson is the global leader of PwC's tax controversy and dispute resolution (TCDR) network and is resident in the Washington, DC office. The TCDR global network includes more than 650 tax controversy professionals, located in more than 45 countries across the globe, who assist multinational companies to prevent, manage, and resolve tax audits and disputes worldwide. Following a prominent legal career spanning 25 years, David has substantial experience in advising multinational corporations (MNCs) on international tax matters, and assisting companies in their efforts to pursue a variety of measures aimed at proactively preventing, efficiently managing, and favourably resolving tax audits and disputes worldwide. Over the years, David has participated in more than 250 tax controversies involving audits and disputes between MNCs and the IRS, as well as dozens of other revenue authorities around the world. Many of these tax disputes were resolved at the audit level or through the proactive use of administrative appeals, mediation, arbitration, APAs, or the competent authority/MAP process. Other controversies were docketed in a US court of law, proceeded to trial, and resulted in important decisions for MNCs, including cases involving transfer pricing (Bausch & Lomb I), the foreign tax credit (Ampex), competent authority matters (Yamaha), the definition of 'manufacturing' for Subpart F purposes (Bausch & Lomb II), foreign currency (Carborundum), and intellectual property rights (Exide/Exxon). David also participated in several landmark tax cases before the US Supreme Court, including the Barclays Bank, Boeing, and Goodyear cases. David has been described as "one of the top five tax controversy experts in the US," and he received recognition as a "leading attorney" in US tax litigation by Chambers US, and as one of the world's top 25 transfer pricing specialists. In addition, David received a Meritorious Service Certificate from the Treasury Department and IRS, and has been an adjunct professor at Georgetown University Law Center, where he continuously taught courses for 25 years relating to international corporate income taxation. David received his MLT from Georgetown University Law School, and his JD, with honours, and BA, with distinction, from the University of Mississippi. David also has been admitted to practice before the US Tax Court, the US Court of Federal Claims, numerous US Federal Courts of Appeal, and the US Supreme Court.
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Charles Triplett |
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Mayer Brown1999 K Street, NW Washington, DC 20006-1101 US Tel: +1 202 263 3262 Fax: +1 202 263 5262 Email: ctriplett@mayerbrown.com Website: www.mayerbrown.com Charles Triplett is a widely experienced tax lawyer and adviser whose practice focuses especially on matters of international tax. He served for 16 years with the US Internal Revenue Service, where his primary concentration was placed on international tax issues, and particularly on transfer pricing. His responsibilities included major litigation of Eli Lilly and GD Searle cases; creation and development of the world's first advance pricing agreement programme; numerous legislative efforts and Congressional testimony; and representation of the US at various international bodies, such as the OECD. In the course of his private practice, Charles has emphasised cross-border issues affecting such industries as automotive and parts, computer products and peripherals, semiconductors, telecommunications, engineering, pharmaceuticals, food products, financial products, banking, insurance and energy. He has been cited in leading professional publications, including the International Tax Review's Guide to the World's Leading Tax Advisers'; 'The Best of the Best', 'The World's Leading Transfer Pricing Lawyers'; and 'The World's Leading Transfer Pricing Advisers', (in 2000, receiving the most votes among nominees for this mention). He is also recognised as a leading transfer pricing adviser in Expert Guides 'The Best of the Best USA 2013 – Transfer Pricing'. Charles joined Mayer Brown in 1994. Before that, he was with Shearman & Sterling in Washington, DC. His experience with the Internal Revenue Service (1977–1993) includes: special assistant to the chief counsel (1992–1993); deputy associate chief counsel, international (1986–1992); national tax shelter coordinator (1984–1986); and special trial attorney (1983–1984). Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."
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Todd Welty |
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Dentons2000 McKinney Ave Suite 1900 Dallas, TX 75201 US Direct line: +1 214 259 0953 Email: todd.welty@dentons.com Website: www.dentons.com As the US head of the Dentons tax controversy and litigation practice, Todd has been recognised as a leader in his practice by Chambers USA, The Best Lawyers in America, and International Tax Review. He is also a fellow of the American College of Tax Counsel. He represents a broad range of clients including Fortune 100 companies, large non-US multinational companies, closely held businesses, ultra high-net-worth individuals and tax advisers. Todd has extensive experience in resolving civil tax matters at all stages of a tax dispute, including IRS examinations, fast-track appeals, administrative appeals, post-appeals mediation and, if necessary, litigation in any US court. In addition, Todd has represented numerous clients in proceedings involving IRS administrative criminal investigations, grand jury investigations, malpractice claims and indemnity claims. The vast majority of Todd's cases are resolved administratively and without becoming public. However, as a seasoned trial lawyer, he has achieved significant trial victories as lead counsel in major civil and criminal tax cases. His substantive and procedural tax knowledge combined with his first chair courtroom abilities place him among a small group of experienced tax trial lawyers in high dollar tax disputes. Often, this skillset helps him achieve settlements with the IRS and DOJ Tax Division without the need for trial. Todd frequently speaks at conferences, including the American Bar Association Tax Section, the NYU Tax Controversy Forum and the National Institute on Tax Controversy. Education
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Gary Wilcox |
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PwC600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: +1 202 312 7942 Fax: +1 678 529 4506 Email: gary.wilcox@us.pwc.com Website: pwc.com/taxcontroversy Gary Wilcox is a principal with PricewaterhouseCoopers in Washington, DC, where he co-leads a US controversy team that actively advises clients during the audit management and appeals and resolution phases of an IRS dispute. Gary also works closely with corporate and international specialists in cross-border transactions to help clients prepare for potential controversy. Gary's team frequently seeks rulings and other guidance for clients from IRS and Treasury as a means of proactively avoiding tax controversies. Gary was recently a partner with Morgan Lewis, where he headed up the firm's tax practice. Before taking up that role, he served as deputy chief counsel (Technical) in the IRS Office of Chief Counsel and, earlier, as a leader of PwC's mergers & acquisitions practice. Gary was litigation counsel to Iberdrola and ScottishPower in NAGP v. Commissioner, a 2012 Tax Court decision that upheld nearly $1 billion of taxpayer's interest deductions on cross-border intercompany debt. A frequent lecturer on corporate tax issues, Gary is an author of the BNA Tax Management Portfolio entitled Corporate Acquisitions- (A), (B), and (C) Reorganisations. Gary has an LLM in taxation from New York University, a JD with highest honours from the University of Oklahoma and an undergraduate degree (cum laude) from Texas Tech University.
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Joel Williamson |
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Mayer Brown71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7229 Fax: +1 312 706 9204 Email: jwilliamson@mayerbrown.com Website: www.mayerbrown.com Joel Williamson is widely acknowledged as one of the nation's leading tax attorneys and litigators. He has litigated more than 60 tax cases. His experience includes the trial of six major IRC § 482 transfer pricing cases, including Eli Lilly, GD Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, and United Parcel Service. Presently, Joel is serving as lead trial counsel in Guidant LLC and Eaton, two cases involving IRC § 482 issues. Joel has also litigated numerous cases involving economic substance, including the United Parcel Service case just noted, as well as the Flextronics, ConEd and Tribune. In the international tax area, Joel has litigated subpart F, constructive triangular dividend and R&D moratorium issues, Gulf Oil, The Limited, and Boeing, and Brazilian and other foreign tax credits for banks, Bankers Trust and Riggs Bank, as well as foreign versus domestic-source income IRC § 863(b) questions, Intel. In addition, Joel has litigated IRC § 338 corporate acquisition related issues, like debt-versus-equity involving Nestlé's acquisition of Carnation, Nestlé. Joel is presently the lead trial attorney in the mega Tyco debt versus equity cases. Joel has litigated significant procedural questions, including the proper role of IRS trial counsel in the audit examination process, Westreco (Nestlé). He is also experienced in summons enforcement actions for both foreign and domestic records. Joel is proud to have been recognised by Chambers USA as a 'leading lawyer' in each of the years 2003 to 2014. In addition, he was recognised by Legal 500 as a 'leading lawyer' in 2008, 2011, 2012, 2013 and 2014, describing Joel as a "highly skilled trial attorney possessing great judgment". Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 United States Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. Joel served as an Officer in the United States Army from 1970 through 1972, assigned to the Offices of the Staff Judge Advocate, 12th Support Brigade, Ft. Bragg, NC, and subsequently to Saigon Support Command, the Republic of South Vietnam. After his return from Vietnam in 1972, Joel joined the Chief Counsel's Office, US Department of Treasury. In 1978, he was appointed one of 20 special trial attorneys located throughout the US. Joel joined Mayer Brown in 1986 as a partner.
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Todd Wolosoff |
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Deloitte Tax1633 Broadway New York, NY 10019-6754 US Tel: +1 212 492 4890 Email: twolosoff@deloitte.com Website: www.deloitte.com Todd Wolosoff is the Deloitte global and US leader for transfer pricing, and the Deloitte Tax transfer pricing managing partner. He is based in the firm's New York office. He has nearly 30 years of experience as a partner in representing multinational corporations in transfer pricing and international tax matters. Todd was promoted to his current roles in 2012 and 2011 respectively. Previously, Todd was the partner-in-charge of transfer pricing for the northeast United States and the leader of the tri-state transfer pricing group since its inception in 1990. He is a founding member of the Deloitte Tax national transfer pricing leadership group. In Todd's global leadership role, he is responsible for creating and implementing strategy and providing vision and leadership to Deloitte's network of nearly 2,000 transfer pricing professionals worldwide. In his US transfer pricing leadership role, Todd is responsible for all aspects of the US transfer pricing group including strategy, operations, hiring and human resources. Todd has approximately 50 partners, principals and directors and hundreds of professionals as part of his team. Todd serves as an adviser to several of the world's largest multinationals and has conducted numerous transfer pricing planning studies in virtually all industries, with a particular focus on pharmaceuticals, electronics, financial services, consumer products, automotive, TMT, and fashion and beauty products, for both inbound and outbound taxpayers. He has been recognised by Euromoney as one of the world's leading transfer pricing advisers and was one of four Deloitte tax partners selected by Mondaq in its survey of the top attorneys in the US. Todd is also recognised by International Tax Review as one of the world's leading tax advisers. Todd holds a BS in economics from the Wharton School, the University of Pennsylvania, a JD from St. John's School of Law, and an LLM from New York University School of Law. Todd is a licensed attorney and a CPA, as well as a member of the American Bar Association, the New York State Bar Association, the American Institute of Certified Public Accountants, and the New York Society of Certified Public Accountants.
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